PTAB

IPR2016-00672

Zepp Labs Inc v. Blast Motion Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Motion Capture Element
  • Brief Description: The ’521 patent discloses a motion capture system designed for low-power, accurate data capture, particularly for sports applications. The system comprises a memory, sensor, radio, and a microcontroller configured to identify valid motion events by using thresholds and eliminating false positives before storing and transmitting the relevant data.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mahajan, Edis, Su, and Wilson - Claims 1, 5, 7, 11, 14, 15, and 19 are obvious over Mahajan in view of Edis, Su, and Wilson.

  • Prior Art Relied Upon: Mahajan (Application # 2006/0025229), Edis (Application # 2010/0144414), Su (Application # 2010/0323794), and Wilson (Application # 2010/0103269).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mahajan disclosed the foundational motion capture system for a golf club, including a sensor, microcontroller, and radio for wireless data transmission. However, to arrive at the claimed invention, a person of ordinary skill in the art (POSITA) would have modified Mahajan with teachings from other references. Edis was cited for its explicit teaching of using different data thresholds to trigger the capture of specific event data (e.g., a punch or a golf swing). Su was cited for its method of eliminating false positive motions by comparing sensor data patterns against parameters within a time interval. For claim 1’s limitation of estimating initial orientation from two points in time, Petitioner asserted Wilson taught this specific technique for a sensor-based controller.
    • Motivation to Combine: A POSITA would combine these references to improve upon Mahajan’s basic system. All references operate in the same technical field of sensor-based motion analysis for sports and gaming. The motivation would be to enhance the accuracy and efficiency of Mahajan’s device by incorporating Edis’s more sophisticated threshold-based event detection and Su’s specific methods for false positive rejection, which Mahajan’s system implied but did not detail. Wilson’s orientation algorithm represented a known technique to improve orientation tracking, a key function of such systems.
    • Expectation of Success: A POSITA would have an expectation of success because combining the references involved implementing known software and algorithmic techniques (thresholding, pattern matching, orientation calculation) on a standard, well-understood hardware platform (microcontroller-based sensor module) as disclosed by Mahajan.

Ground 2: Obviousness over Mahajan, Edis, Su, Wilson, and Oleson - Claim 4 is obvious over the combination for Ground 1 further in view of Oleson.

  • Prior Art Relied Upon: Mahajan (Application # 2006/0025229), Edis (Application # 2010/0144414), Su (Application # 2010/0323794), Wilson (Application # 2010/0103269), and Oleson (Application # 2009/0048044).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed dependent claim 4, which adds the limitation of transmitting data on an event-by-event basis, periodically, or when requested by a computer. Petitioner argued that while the primary combination taught event-based transmission, Oleson explicitly disclosed a motion monitor that could transmit data periodically when in an active mode or upon receiving a request from a paired device like a mobile phone.
    • Motivation to Combine: A POSITA would combine Oleson with the system from Ground 1 as a matter of simple design choice. Providing multiple, well-known data transmission modes (event-based, periodic, on-request) would increase the flexibility and utility of the motion capture device, allowing it to adapt to different use cases and power constraints.
    • Expectation of Success: Implementing these standard communication protocols on the base system would be a routine task for a POSITA.

Ground 3: Obviousness over Mahajan, Edis, Su, Wilson, and Johnson - Claim 6 is obvious over the combination for Ground 1 further in view of Johnson.

  • Prior Art Relied Upon: Mahajan (Application # 2006/0025229), Edis (Application # 2010/0144414), Su (Application # 2010/0323794), Wilson (Application # 2010/0103269), and Johnson (Patent 5,610,590).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground targeted dependent claim 6, which requires the microcontroller to power off if no motion is detected for a predefined time. Petitioner asserted that Johnson expressly taught a motion detection device that enters a power-saving "sleep mode" by disabling components when no motion is detected, preserving battery life.
    • Motivation to Combine: A POSITA would be motivated to incorporate Johnson’s power-saving technique into the battery-powered motion capture device of Ground 1 for the obvious and predictable benefit of extending battery life, a critical consideration for portable electronic devices.
    • Expectation of Success: Integrating a sleep mode based on motion inactivity was a well-known and common practice in the design of such sensor systems.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for claim 9 over the primary combination and Eyestone (for firmware updates), and for claims 14 and 16 over the primary combination and Dugan (for comparing current data against saved data and for using a cellular interface).

4. Key Claim Construction Positions

  • "said data": Petitioner contended that the term "said data" as used in multiple claims lacked a clear antecedent basis and was therefore indefinite. In the alternative, should the Board construe the term, Petitioner argued that its broadest reasonable interpretation should be "data that comprises sensor values," consistent with the patent owner's position in related district court litigation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 4-7, 9, 11, 14-16, and 19 of Patent 8,903,521 as unpatentable.